Cited by

Opinions in Minnesota that cite State v. Hahn, 799 N.W.2d 25.

61 citing documents.

State of Minnesota v. Quenton Tyrone Williams Minn. Ct. App. 2026
See Taylor, d at 20 (stating that “neutral reasons” for a delay like “overcrowded courts” do not weigh heavily against the state); (noting that docket congestion is not a good cause for delay, but it also does not weigh heavily against the state); (stating that “administrative delay, by itself, is generally insufficient to violate a defendant’s speedy-trial right in the absence of a deliberate attempt to delay trial”) , rev. denied (Minn. Aug.
State of Minnesota v. Rajuan Marquice Jones Minn. Ct. App. 2026
See State v. Hahn , (“[W]hen the overall delay in bringing a case to trial is the result of the defendant ’s actions, there is no speedy trial violation.” (quotation omitted)), rev. denied (Minn. Aug.
State of Minnesota v. Dustan Charles Schmitt Minn. Ct. App. 2026
28, 2017); (“Judicial estoppel has not yet been adopted by the Minnesota courts, and it is beyond our mandate to adopt it now.”), rev. denied (Minn. Aug.
State of Minnesota v. Frank John Rakowiecki Minn. Ct. App. 2026
State of Minnesota v. Frank John Rakowiecki Minn. Ct. App. 2026
In cases following Bauer and Harstad, but before Thoresen, we have also noted that the doctrine of judicial estoppel has not been recognized in Minnesota and that it is not this court’s “mandate to adopt it.” 17 rev. denied (Minn. Aug.
State of Minnesota v. Daniel Robert Voeller Minn. Ct. App. 2025
why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011) (quotation omitted), rev. denied (Minn. Aug.
State of Minnesota v. James Demetrius Redd Minn. Ct. App. 2025
“Unfair prejudice ‘does not mean the damage to the opponent’s case that results from the legitimate probative force of the evidence; rather, it refers to the unfair advantage that results from the capacity of the evidence to persuade by illegitimate means.’” (d 191, 197 n.3 (Minn. 1995)), rev. denied (Minn. Aug.
State of Minnesota v. Decarieon Dupra Scurlock Minn. Ct. App. 2025
why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011) (quotation omitted), rev. denied (Minn. Aug.
State of Minnesota v. Jeremy Jyrone White Minn. Ct. App. 2025
State of Minnesota v. Jeremy Jyrone White Minn. Ct. App. 2025
(providing that “[d]elays caused by defense motions generally weigh against the defendant”), rev. denied (Minn. Aug.
State of Minnesota v. Michael Drew Williams Minn. Ct. App. 2024
(citing Barker, 407 U.S. at 529, 531) , rev. denied (Minn. Aug.
State of Minnesota v. Larry Dusaun Gray Minn. Ct. App. 2024
why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011) (quotation omitted), rev. denied (Minn. Aug.
State of Minnesota v. Anthony Lee Prellwitz Minn. Ct. App. 2024
State of Minnesota v. Anthony Lee Prellwitz Minn. Ct. App. 2024
Under Minnesota’s criminal procedure rules, “trial is to commence within 60 days from the date of the demand unless good cause is shown why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011) (quotation omitted), rev. denied (Minn. Aug.
State of Minnesota v. Malcolm Jamal Allen Minn. Ct. App. 2023
State of Minnesota v. Ronald Anthony Falk Minn. Ct. App. 2022
State of Minnesota v. Douglas Wayne Young Minn. Ct. App. 2022
“Unfair 5 prejudice ‘does not mean the damage to the opponent’s case that results from the legitimate probative force of the evidence; rather, it refers to the unfair advantage that results from the capacity of the evidence to persuade by illegitimate means.’” ( n.3 (Minn. 1995)), rev. denied (Minn. Aug.
State of Minnesota v. Randip E. Satoskar Minn. Ct. App. 2022
(“ Appellant’s attempts to delay the trial after requesting a speedy trial weigh against him for the purposes of a Barker analysis.”), rev. denied (Minn. Aug.
State of Minnesota v. Toman Davin Matthews Minn. Ct. App. 2022
See DeRosier, d at 109; d 25, 31 (Minn. App. 2011), rev. denied(Minn. Aug.
State of Minnesota v. Shawn Elson Randall Minn. Ct. App. 2021
“Delays caused by defense motions generally weigh against the defendant.” rev. denied (Minn. Aug.
State of Minnesota v. Joshua Bernard Smith Minn. Ct. App. 2020
why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011); see also Minn. R. Crim.
State of Minnesota v. Derrick Lee Riddle Minn. Ct. App. 2020
“Mere court congestion is insufficient” to justify delays, but administrative delays, by themselves, are “generally insufficient to violate a defendant’s speedy-trial right in the absence of a deliberate attempt to delay trial ,” State v. Hahn , , 32 (Minn. App. 2011).
State of Minnesota v. Vernon Kingbird, Jr. Minn. Ct. App. 2020
When analyzing whether delay causes prejudice to a defendant’s interest in avoiding undue anxiety and concern, the question is whether a defendant suffers anxiety that “is greater than the anxiety of any other defendant.” review denied (Minn. Aug.
State of Minnesota v. Kaylen Demond Nelson Minn. Ct. App. 2019
When analyzing w hether delay causes prejudice to a defendant’s interest in avoiding undue anxiety a nd concern, the question is whether a defendant suffers anxiet y t h a t “ i s g r e a t e r t h a n t h e anxiety of any other defendant.” review denied (Minn. Aug.
State of Minnesota v. Dean Allen Benter Minn. Ct. App. 2019
Length of delay “In Minnesota, a delay of more than 60 days from the date of the speedy -trial demand is presumptively prejudicial, triggering review of the remaining three [ Barker] factors.” review denied (Minn. Aug.
State of Minnesota v. La’Marr Merrel Wade Minn. Ct. App. 2019
“[A]dministrative delay, by itself, is generally insufficient to violate a defendant ’s speedy-trial right in the absence of a deli berate attempt to delay trial.” review denied (Minn. Aug.
State of Minnesota v. Dameion Deshawn Hill Minn. Ct. App. 2018
“[O]vercrowded courts should be weighted less heavily but nevertheless should be considered,” Barker, 407 U.S. at 531, 92 S. Ct. at 2192, but “administrative delay, by itself, is generally insufficient to violate a defendant’s speedy -trial right in the absence of a deliberate attempt to delay trial ,” State v. Hahn , review denied (Minn. Aug.
State of Minnesota v. Pao Choua Xiong Minn. Ct. App. 2018
“The designation of out-of-state convictions as felonies, gross misdemeanors, or mi sdemeanors shall be governed by the offense defin itions and sentences provided in M innesota law.” (quotation omitted), review denied (Minn. Aug.
State of Minnesota v. Seekou Lee Minn. Ct. App. 2018
10 “The responsibility for promptly bringing a case to trial rests with the state.” review denied (Minn. Aug.
State of Minnesota v. Glen Dale Acon Minn. Ct. App. 2018
why the defendant should not be brought to trial within that period.” State v. Hahn , -30 (Minn. App. 2011), review denied (Minn. Aug.
State of Minnesota v. Keith Lamar Robinson Minn. Ct. App. 2018
why the defendant should not be brought to trial within that period.” State v. Hahn , -30 (Minn. App. 2011) (alteration in original) (quoting DeRosier, d at 108-09); see also Minn. R. Crim.
State of Minnesota v. William Lee Carter Minn. Ct. App. 2018
why the defendant should not be brought to trial within that period.” -30 (Minn. App. 2011) (quotation omitted), review denied (Minn. Aug.
State of Minnesota v. Ronald Lee Conway Minn. Ct. App. 2018
why the defendant should not be brought to tr ial within that period.” -30 (Minn. App. 2011); see also Minn. R. Crim.
Antonio Xavier Daniels v. State of Minnesota Minn. Ct. App. 2018
c. Assertion of right to speedy trial Under the third factor, “[a] defendant’s assertion of the right to a speedy trial need not be formal or technical, and it is determined by the circumstances.” d 25, 32 (Minn. App. 2011), review denied (Minn. Aug.
State of Minnesota v. James Franklin Patten Minn. Ct. App. 2017
review denied (Minn. Aug.
State of Minnesota v. Gideon Wesseh Chea Minn. Ct. App. 2017
State v. Hahn , review denied (Minn. Aug.
State of Minnesota v. Robert Earl Leatherberry Minn. Ct. App. 2017
State v. Hahn , review denied (Minn. Aug.
State of Minnesota v. Quentin Todd Chute 887 N.W.2d 834 Minn. Ct. App. 2016
State of Minnesota v. Quentin Todd Chute 887 N.W.2d 834 Minn. Ct. App. 2016
“Delays caused by defense motions generally weigh against the defendant.” State v. Hahn, 14 review denied (Minn. Aug.
State of Minnesota v. Jeremiah James Shefelbine Minn. Ct. App. 2016
State of Minnesota v. Jeremiah James Shefelbine Minn. Ct. App. 2016
“Delays caused by defense motions generally weigh against the defendant.” State v. Hahn, 4 review denied (Minn. Aug.
State of Minnesota v. Trevon Fuller Minn. Ct. App. 2016
State of Minnesota v. Trevon Fuller Minn. Ct. App. 2016
“Delays caused by defense motions generally weigh against the defendant.” review denied (Minn. Aug.
State of Minnesota v. Derrick Lee Riddle Minn. Ct. App. 2016
State of Minnesota v. Derrick Lee Riddle Minn. Ct. App. 2016
review denied (Minn. Aug.
State of Minnesota v. Marlow Shelton McDonald Minn. Ct. App. 2016
State of Minnesota v. Marlow Shelton McDonald Minn. Ct. App. 2016
15 “Delays caused by defense motions generally weigh against the defendant.” review denied (Minn. Aug.
State of Minnesota v. Kevin Charles Owens Minn. Ct. App. 2016
State of Minnesota v. Kevin Charles Owens Minn. Ct. App. 2016
principally because his own motions were the primary reason for much of the delay”); -32 (Minn. App. 2011) (concluding that the second Barker factor weighed against the defendant because of his motions and “various requests for continuances and postponements”), review denied (Minn. Aug.
State of Minnesota v. Scott Michael Popa Minn. Ct. App. 2015